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ANALYSIS
Cutting edge analysis on tax issues.
International review for May 2023
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
The reserved investor fund regime: restricted or unrestricted, that is the question
Martin Shah
Martin Shah (Simmons
& Simmons) reviews the proposed reserved investor fund regime, while
Melville Rodrigues (Apex Group) says why it is needed.
The electricity generator levy: an introduction
Hiral Bhatt
Hiral Bhatt (Alvarez & Marsal) examines how the new levy will work and uncovers some uncertainties yet to be resolved.
HMRC consultation on the taxation of DeFi transactions
David Haworth
Alex Cheetham
HMRC has released a second consultation on the taxation of decentralised finance cryptoasset lending and staking transactions. David Haworth and Alex Cheetham (Freshfields Bruckhaus Deringer) review the proposals.
The UK’s international disclosure rules: where are we now?
Sharon Baynham
Sharon Baynham (KPMG) explains how the new reporting rules differ from DAC 6 and what action tax professionals should be taking.
Private client review for May 2023
Edward Reed
Tristan Honeyborne
The burden of proof as regards the taxpayer behaviour, late appeals and cautionary tales for IHT planning are among the topics featuring in this month’s review by Edward Reed and Tristan Honeyborne (Macfarlanes).
In conversation with... FTT President Greg Sinfield
Anthony Inglese
Anthony Inglese (former general counsel to HMRC) talks to Judge Sinfield, president of the FTT Tax Chamber, about his career and current work priorities.
EMI takes its turn in the spotlight
Claire Matthews
Tax-favoured share plans are firmly in the spotlight at the moment.
Claire Matthews (Taylor Wessing) reminds us how EMI options work and
reviews recent changes.
Where next for UK REITs?
Rob Williams
Rob Williams (FTI Consulting) considers the latest refinements to the REIT regime and the further changes that may be on the horizon.
The saga continues: implementing Pillar Two in the UK
Jack Gifford
Chris Sanger
The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and
Jack Gifford (EY).
Go to page
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453
EDITOR'S PICK
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
1 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
2 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
3 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
4 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
5 /7
The new Securities Transfer Tax: business as usual?
Georgina West
6 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
7 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
NEWS
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Tax receipts rise, but borrowing exceeds OBR forecast ahead of Budget
Construction industry scheme compliance
CIOT urges legislative change on pre-development costs
CIOT backs faster land remediation relief but warns on planning link
Only one in ten highest earners pay top tax rate, says CenTax
CASES
Read all
Environmental Services Ltd v HMRC
Sir J Griffin v HMRC
Minerva Research Labs Ltd v HMRC
Other cases that caught our eye: 25 September 2026
J Scheckter v HMRC
IN BRIEF
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Substantial
Modernising the taxation of distributions: why now?
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
MOST READ
Read all
J Scheckter v HMRC
Consultation tracker
Sir J Griffin v HMRC
Redrawing the line: modernising the taxation of distributions
DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5